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2013 (12) TMI 956 - ITAT JODHPURValidity of assessment u/s 263 - Held that:- As per section 263 - CIT must have some material(s) which would enable him to form a prima facie opinion that the order passed by the Assessing Officer is erroneous in so far as it is prejudicial to the interest of the Revenue - The AO cannot revise an order on grounds regarding which the assessee was not show cause otherwise also the assessment order was made u/s 147/148 r.w.s. 143(3) of the Act and the AO has computed assessee's income after making reasonable and due inquiries - The assessee is not found to have been indulging in the purchase and sales of any immovable property - The twin condition of Section 263 are not fulfilled and, thus, the order cannot be revised - Decided in favour of assessee.
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